UNC Modification Proposal 0295 - “Allocation of Daily NTS Entry Capacity Within-Day” Richard Fairholme

A Summary of the Current Problem Scope for: No prescribed timescales Entry capacity allocations made too late to be of commercial use Security of Supply implications A bid for daily (firm) entry capacity is submitted on Gemini Disputes as regards when allocations should be made National Grid thinks about it… Shipper is left waiting... Meanwhile… Time is running out!

This Proposal Max. 1 hour 15 minutes or A bid is submitted (or existing bid amended) on the ‘Gemini’ system On the next hour bar, National Grid NTS must consider the bid (i.e. initiate a Capacity Allocation Period) Shipper’s bid must be either accepted or turned down in next Capacity Allocation Period. Max. 1 hour 15 minutes

The Case for Change Aim of Proposal is to codify existing operational ‘best practice’ by National Grid NTS - NOT to introduce a completely new way of working. ‘Best practice’ works well under favourable conditions, but if the system is pushed (e.g. an entry terminal failure on the day) , where is the guarantee that Shippers’ daily capacity bids will be dealt with in a timely and consistent manner?

The Case for Change The existing UNC rules are ambiguous and open to interpretation as to when during the day National Grid NTS must allocate capacity once a bid has been submitted. If the UNC rules were to be strictly interpreted, National Grid NTS may only have to initiate one capacity allocation period (per ASEP) each gas Day – regardless of number / timing of Shipper bids submitted. If UNC Mod 284 is implemented, due to cost pressures, daily entry capacity bookings are likely to more closely match actual gas flows. = a much more active within-day market This Mod Proposal provides added flexibility and certainty for Shippers to bid for within-day firm entry capacity: Important for those Shippers with a variable supply portfolio.

Any Questions?